Timeline · EU AI Act
EU AI Act Deadlines & Timeline
The EU AI Act has been in force since August 2024 – but obligations apply in phases depending on system type. Art. 50 transparency obligations apply from 2 August 2026. The main deadline for high-risk AI systems under Annex III was postponed to 2 December 2027 by the Digital Omnibus; product-integrated AI under Annex I has until 2 August 2028.
Key deadlines at a glance
Regulation enters into force
The EU AI Act officially entered into force. No immediate obligations for companies yet, but the starting gun for the transition phases.
Bans for unacceptable risk
The prohibitions under Art. 5 apply: prohibited are AI systems for social scoring, subliminal manipulation, biometric categorisation by sensitive characteristics and real-time remote identification in public.
GPAI models (general-purpose AI)
Obligations for providers of General-Purpose AI (GPAI) models take effect: transparency obligations, technical documentation and – for systemic risk – enhanced risk mitigation measures. The governance provisions and the penalty framework also become applicable.
Transparency obligations & general applicability
Art. 50 transparency obligations apply (e.g. labelling of AI interactions and AI-generated content); the remaining provisions of the Regulation become generally applicable. The main deadline for high-risk AI under Annex III was postponed to December 2027 by the Digital Omnibus (see below).
High-risk AI under Annex III (Digital Omnibus)
Latest application date for high-risk AI systems under Annex III: technical documentation, conformity assessment, EU database registration, human oversight and ongoing monitoring. The Digital Omnibus moved this main deadline from August 2026 to 2 December 2027.
Product-integrated AI (Annex I)
AI systems embedded as safety components in products under Annex I of the EU AI Act (e.g. medical devices, machinery) have until 2 August 2028. This applies to already-marketed products that require a new conformity assessment.
What must companies complete by December 2027?
- Inventory all AI systems and determine risk classes
- Identify high-risk AI systems under Annex III
- Create technical documentation according to Annex IV
- Conduct or commission conformity assessment procedures
- Establish internal governance and human oversight mechanisms
- Register high-risk AI in the EU database
How long does preparation take?
Experience shows: companies with multiple high-risk AI systems typically need 3–6 months for full compliance preparation. Anyone who has not yet started should begin immediately.
- 2–4 weeks
- Build AI inventory
- 4–8 weeks
- Risk classification and documentation
- 4–8 weeks
- Conformity assessment and measures
- Ongoing
- Monitoring and updating
Frequently asked questions about EU AI Act deadlines
What happens if my company misses the deadline?
From each respective date (Art. 50 transparency: August 2026; high-risk under Annex III: December 2027), market surveillance authorities can take action. Besides measures up to market withdrawal, fines under Art. 99 apply: up to €35 million or 7% of worldwide annual turnover for prohibited practices, up to €15 million or 3% for breaches of other obligations, and up to €7.5 million or 1% for supplying incorrect or misleading information to authorities – whichever is higher. For SMEs and start-ups, the lower amount applies.
Which deadline applies to which AI systems?
Art. 50 transparency obligations apply from August 2026. The main deadline for high-risk AI under Annex III is – postponed by the Digital Omnibus – 2 December 2027. Product-integrated AI under Annex I (e.g. medical devices, machinery) has until August 2028. AI systems with minimal or limited risk have fewer requirements and no hard deadline in this sense.
What about existing AI systems that were in operation before 2024?
High-risk AI systems placed on the market or put into service before the application date generally only fall under the new requirements if they are significantly modified from 2 December 2027 onwards. They must then fully comply with the requirements.
Do SMEs have to meet the same deadlines?
Essentially yes, but the EU AI Act includes simplified procedures and reduced requirements for SMEs. The same deadlines still apply – just the effort for some obligations is lower.
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